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`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`VERANCE CORPORATION,
`Petitioner,
`
`v.
`
`MZ AUDIO SCIENCES, LLC,
`Patent Owner.
`_____________
`
`Case No. IPR2022-01544
`Patent No. 7,289,961
`_____________
`
`
`
`
`PETITIONER’S UNOPPOSED MOTION TO WITHDRAW CERTAIN
`COUNSEL
`
`
`
`
`
`
`
`
`
`

`

`
`
`I.
`
`STATEMENT OF RELIEF REQUESTED
`Pursuant to 37 C.F.R. § 42.10(e) and the Board’s July 3, 2023 email
`
`authorizing this motion, Petitioner Verance Corporation respectfully requests that
`
`the Board authorize the withdrawal of Lead and Backup Counsel Richard F. Giunta,
`
`Thomas A. Franklin, and Michael N. Rader for Sony Petitioners in this proceeding.
`
`II. REASONS FOR RELIEF REQUESTED
`On June 26, 2023, the Board entered an Order Terminating Sony Group
`
`Corporation (Japan), Sony Corporation of America, Sony Interactive Entertainment
`
`LLC, Sony Pictures Entertainment Inc., and Sony Electronics Inc. (collectively
`
`“Sony Petitioners”) from the instant Inter Partes Review (Paper 17). As previously
`
`noted in Petitioner’s Power of Attorney submitted in this proceeding, Attorneys
`
`Giunta, Franklin, and Rader represented only the Sony Petitioners, and do not have
`
`an attorney-client relationship with Verance Corporation. Paper 6 at 1 n.1. Given
`
`that the Sony Petitioners have been terminated from this proceeding, and Verance
`
`Corporation is now the sole Petitioner in this trial, it is appropriate to allow counsel
`
`for the Sony Petitioners to withdraw. Good cause therefore exists for the Board to
`
`authorize Attorneys Giunta, Franklin and Rader withdrawal pursuant to 37 C.F.R.
`
`§ 42.10(e).
`
`Patent Owner has been consulted and does not object to withdrawal of
`
`Attorneys Giunta, Franklin and Rader. Further, Counsel for Sony Petitioners have
`
`- 1 -
`
`

`

`
`
`been consulted and do not object to this motion. No changes to the schedule would
`
`be required based on this change in counsel. Petitioner will continue to be
`
`represented by a lead counsel and at least one back-up counsel in compliance with
`
`37 C.F.R. § 42.10(a). Updated Mandatory Notices and an Updated Power of
`
`Attorney are being submitted herewith for remaining Petitioner Verance
`
`Corporation.
`
`Based on the above, granting this motion will not hinder the economy, the
`
`integrity of the patent system, the efficient administration of the Office, or the ability
`
`of the Office to timely complete this proceeding. See 35 U.S.C. § 316(b).
`
`III. CONCLUSION
`Petitioner respectfully requests that the Board authorize the withdrawal of
`
`Richard F. Giunta, Thomas A. Franklin, and Michael N. Rader from this proceeding.
`
`
`Date: July 5, 2023
`
`
`
`Respectfully submitted,
`Verance Corporation
`
`/Babak Tehranchi/
`Babak Tehranchi, Reg. No. 55,937
`Thomas Millikan, Reg. No. 72,316
`PERKINS COIE LLP
`11452 El Camino Real, Suite 300
`San Diego, CA 92130-2080
`
`
`
`
`- 2 -
`
`

`

`
`
`CERTIFICATE OF SERVICE
`The undersigned certifies service on the Patent Owner, pursuant to 37 C.F.R.
`
`§ 42.6(e), by electronic (e-mail) delivery of a true copy of the foregoing
`
`PETITIONER’S UNOPPOSED MOTION TO WITHDRAW CERTAIN
`
`COUNSEL to lead and backup counsel of record for Patent Owner as follows:
`
`Sarah E. Spires, Steven W. Hartsell, Ryan A. Hargrave
`SKIERMONT DERBY LLP
`MZAudioSciences_SDTeam@skiermontderby.com
`
`
`
`Date: July 5, 2023
`
`
`
`
`
`
`
`By: /Meghan Bright/
`Meghan Bright
`Patent Paralegal
`Perkins Coie LLP
`1201 Third Avenue Suite 4900
`Seattle, WA 98101-3099
`
`- 3 -
`
`

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